Prabhakar Guniganti, Individually, the Guniganti Children's 1999 Trust, and Triple PG Sand Development, LLC v. C & S Components Company, LTD

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ACCEPTED 14-14-00224-CV FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 2/17/2015 3:35:45 PM CHRISTOPHER PRINE CLERK NO. 14-14-00224-CV FILED IN 14th COURT OF APPEALS IN THE FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS HOUSTON, TEXAS 2/17/2015 3:35:45 PM CHRISTOPHER A. PRINE Clerk PRABHAKAR GUNIGANTI, INDIVIDUALLY, ET AL. APPELLANTS, V. C&S COMPONENTS COMPANY, LTD., APPELLEE. ON APPEAL FROM THE 80TH JUDICIAL DISTRICT COURT HARRIS COUNTY, TEXAS HON. LARRY WEIMAN, JUDGE PRESIDING APPELLANTS’ UNOPPOSED FIRST MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S REPLY BRIEF TO THE HONORABLE COURT OF APPEALS: Appellants, Prabhakar Guniganti, Individually, The Guniganti Children’s 1999 Trust, and Triple PG Sand Development, LLC, file this Unopposed First Motion for Extension of Time to File Appellants’ Reply Brief. 1. The deadline for filing Appellants’ Reply Brief is February 19, 2015. 2. This is appellants’ first motion for extension of time to file their reply brief. 3. Appellants request an extension of 21 days; that is, an extension of time to and including March 12, 2015. 4. Counsel could not prepare Appellants’ Reply Brief by the current due date, given proper standards of representation, because of her work in the following matters: a. Conducting the research and drafting post-judgment motions, and analyzing proposed Findings of Fact and Conclusions of Law, in Kyu Im Robinson v. Jess L. Mayfield, et al.; Cause No. 2013-CI-07766; in the District Court of Bexar County, Texas, 131st Judicial District. The trial court’s judgment in that case was signed on February 3, 2015. b. Assisting in the research and drafting of Appellant’s Reply Brief in No. 01-14-00317-CV, Pelco Construction Co. v. Chambers County, Texas, in the First Court of Appeals, Houston, Texas. The brief in that case was filed on February 12, 2015. c. Assisting in the research and drafting of Reply to Respondents’ Joint Response to Petition for Review in No. 14-0656; MBI Global, L.L.C. v. Hunter Buildings & Manufacturing, L.P., et al.; in the Supreme Court of Texas. That reply was filed on February 3, 2015. -2- 5. Counsel would show that she is a solo practitioner and is solely responsible for the work necessary to prepare Appellants’ Reply Brief in this case. PRAYER For the reasons stated, appellants request that this Court grant this motion and extend the time for filing Appellants’ Reply Brief to and including March 12, 2015. Respectfully submitted, JOANN STOREY, P.C. BY: /s/ JoAnn Storey JoAnn Storey State Bar No. 19315300 1005 Heights Boulevard Houston, Texas 77008 Telephone: 713/529-0048 Facsimile: 713/529-2498 Email: storeyj@heightslaw.com Attorney for appellants, Prabhakar Guniganti, Individually, The Guniganti Children’s 1999 Trust, and Triple PG Sand Development, LLC CERTIFICATE OF CONFERENCE Counsel for appellee does not oppose this motion. /s/ JoAnn Storey JoAnn Storey -3- CERTIFICATE OF COMPLIANCE Relying on the word count function in the word processing software used to produce this document, I certify that the number of words in this motion is 541. This motion complies with the typeface requirements of TRAP 9.4(e) because it uses a conventional typeface no smaller than 14-point (WordPerfect X4 14-point Times New Roman). /s/ JoAnn Storey JoAnn Storey CERTIFICATE OF SERVICE On February 17, 2015, I sent a true and correct copy of the foregoing Appellants’ Unopposed First Motion for Extension of Time to File Appellants’ Reply Brief via EFILE to the following: Dylan B. Russell HOOVER SLOVACEK LLP 5051 Westheimer, Suite 1200 Houston, Texas 77056 Attorneys for appellee, C&S Components Company, Ltd. /s/ JoAnn Storey JoAnn Storey -4-